Documentation requirements

Documentation requirements under the TTPA Regulation refer to the obligations for sponsors and providers of political advertising services to create, maintain, and make available specific records and information about political advertisements. These requirements ensure that political advertising can be verified, audited, and made transparent to the public and supervisory authorities. Proper documentation is essential for accountability and enforcement of transparency rules.

Legal Basis

"Providers of political advertising services shall keep the information referred to in paragraphs 1 and 2 and make it available, upon request, to the competent authorities for supervision and enforcement purposes for a period of five years after the last publication or dissemination of the political advertisement."

— Article 10(3), Regulation 2024/900

Why It Matters

Documentation requirements create accountability in political advertising by ensuring that key information is preserved and accessible for review. This affects sponsors who pay for political ads, publishers who display them, and providers who facilitate their placement or dissemination.

For sponsors, this means keeping records of who authorized the advertisement, what was spent, and what transparency information was provided. For publishers and providers, it means maintaining accessible records of all political advertisements they handled, including who sponsored them, when they ran, and what targeting was used.

These records serve multiple purposes: they enable supervisory authorities to investigate potential violations, support transparency by making information available to the public through repositories, and help ensure that political advertising complies with restrictions on foreign sponsorship and targeting practices. Without proper documentation, enforcement of the TTPA Regulation would be impossible.

Key Points

Five-year retention: All documentation must be kept for five years after the last publication or dissemination of the political advertisement
On-demand access: Records must be made available to competent authorities upon request for supervision and enforcement purposes
Transparency notice records: Documentation must include all elements of the transparency notice provided to the public (sponsor identity, amount paid, period, reach)
Targeting documentation: Where personal data is used for targeting or ad delivery, records must document the legal basis and data sources used
Sponsor obligations: Sponsors must provide accurate information to publishers and providers and keep records of their political advertising activities
Publisher verification: Publishers must document their due diligence efforts to verify sponsor information and ensure compliance with transparency obligations

Documentation requirements vs. Transparency notice

While both involve information about political advertising, they serve different purposes and audiences. A transparency notice is public-facing information that must be displayed with or alongside the political advertisement so that viewers can see who sponsored it and other key details. Documentation requirements, by contrast, refer to the internal records that must be kept by sponsors, publishers, and providers for potential review by authorities.

The transparency notice is what the public sees; documentation requirements are what regulators can audit. For example, a transparency notice might display "Sponsored by Party X | €5,000 spent | 2-9 May 2024 | 100,000 reach" alongside an ad. The documentation requirements mean Party X and the publisher must keep detailed records proving those figures, along with additional information about targeting methods, for five years. Think of the transparency notice as the public receipt, and documentation requirements as the full accounting ledger.

Related Terms

Transparency notice
Political advertising publisher
Provider of political advertising services
Sponsor
Competent authority
Transparency obligations
Targeting techniques
Record-keeping
Supervision and enforcement
Ad repository

Very transparent. Every political ad will be labelled, linked to a transparency notice with detailed information, and online ads will be searchable in a central European repository.

The Network coordinates election-related cooperation between member states. National contact points for TTPA enforcement should be members of this network where possible.

Election campaigns will need to ensure all paid advertising includes proper labels and transparency notices. Sponsors must be prepared to provide required information to all service providers.

Several major platforms currently do not allow paid political advertising, including some large social networks. This limits where political actors can place paid online advertisements.

The TTPA applies from 10 October 2025. Member States had until 10 April 2025 to designate competent authorities, and the Commission must provide label templates by 10 July 2025.

Publishers must ensure completeness and accuracy of certain information but are not required to verify all sponsor claims. They must correct manifestly erroneous information when they become aware of it.

Yes. When a hosting provider and a website both display an ad, both are considered publishers with responsibility for their specific services. Contracts should clarify how they share compliance duties.

If a publisher removes or disables access to a political ad due to illegality or terms violations, they must still provide access to the transparency information for the full seven-year retention period.